In re K.P.

Citations

• 2024 Ohio 2794

Syllabus

PARENTAL TERMINATION – BEST INTEREST: Former R.C. 2151.414(D)(2) set forth a list of circumstances that, if all were found to exist, mandated a finding that permanent custody was in the best interest of the children even assuming that one of the conditions was not met, the trial court considered all of the factors listed in R.C. 2151.414(D)(1) and properly determined under those factors that a grant of permanent custody to the Hamilton County Department of Job and Family Services was in the children's best interest. Clear and convincing evidence supported the juvenile court's finding that mother had abandoned her children when the evidence showed that mother did not contact or visit her children for several months after their removal from the home due to mother's drug abuse and then for nine months while she was incarcerated, even though mother started visiting the two youngest children after she was released from prison. The juvenile court did not err in finding that a grant of permanent custody was in the children's best interest when the evidence showed that despite some progress, mother still had problems with sobriety, housing and mental health, and therefore, she had not remedied the conditions that caused the children to be removed from the home and she could not provide a legally secure placement for them.